Newsletter – Privacy Notice

This Privacy Notice fulfills the information duty towards the customers that are data subjects required by Articles 13 and 14 in the EU General Data Protection Regulation.


PYN Fund Management Ltd (later ”PYN”)
Address: PL 139, 00101 Helsinki (Mannerheiminaukio 1 E)
Phone: 09-270 70 400
Contact person: Eino Laitinen

Name of the filing system

The name of the filing system is Customer and Marketing Filing System.

Publicity of the filing system

The data in the register are not public.

Purpose of personal data processing and legal basis for processing

The purpose of processing personal data is customer service, communication and customer relationship management as well as marketing and sales, also direct marketing, opinion polls and market surveys or any other deliver with address and business development.

The processing of personal data is based on the consent given by the data subject or when it comes to direct marketing, the processing of personal data is based on the controller’s legitimate interest (Article 6 General Data Protection Regulation) to do direct marketing. PYN Fund Management Ltd does not process personal data in automated decision-making.

Data content of the filing system

The filing system might contain data of PYN’s customers and the addressees of the communication and marketing material: person’s first and last name, the name of organisation, email address and information regarding the customer relationship and realising communication, information regarding the use of service, permissions and consents and other possible information gathered within the consent of the data subject.

Regular data sources

The controller mainly receives data directly from the data subjects themselves or via the controller’s website. In addition, it is possible to gather data of realisation of communication with the help of cookies and other similar techniques.

Regular discloses of data and transferring data to third countries

The data will be disclosed in the situations required by legislation’s and authorities’ (for example Financial Supervisory Authority) orders. The data won’t be disclosed to a third party without the data subject’s own consent.

The controller uses MailChimp-email platform that is widely used and regarded as reliable in its communication, which signifies that personal data will be transferred outside of the European Union. MailChimp participates in the EU-U.S. Privacy Shield Framework and the EU General Data Protection Regulation. By subscribing our Newsletter, you accept that the data you give, are transferred to MailChimp’s service. Via MailChimp, we are able to follow the achievement of newsletters when the addressees open the newsletter mails. More about the Privacy Policy of Mailchimp:

Protection principles regarding the filing system

Protecting personal data is part of PYN’s data protection and risk management. The controller has adequate technical, organisational and administrative security procedures in use with which we protect all data in our possession against loss, misuse, unauthorised use, disclosure, changes and destruction.

Right to inspect

The data subject has the right to check the data concerning him or her that is stored in the filing system. In addition, having submitted sufficiently precise and individualised request, he or she has the right to receive data concerning the data subject and documents’ data. The request should be delivered in written form and signed to the following address: PYN Fund Management Ltd, PL 139, 00101 Helsinki or

The right to require the rectification and erasure of data

The controller shall rectify the inaccurate data indicated by the data subject in the filing system. In addition, the controller has a duty to independently inspect the accuracy of data and the fact that data is up-to-date in the filing system. The data subject has also the right to obtain from the controller erasure of the personal data concerning him or her in the register.

Other rights regarding processing of personal data

The data subject has the right to request from the controller restriction of processing the personal data. The data subject has also the right to receive the personal data concerning him or her, which he or she has provided to the controller, in a structured, commonly used and machine-readable format and has the right to transmit those data to another controller. In addition, the data subject is entitled to object to the processing of data, automated decision-making and profiling. Where the processing of personal data is based on the consent given by the data subject, the data subject has the right to withdraw the consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. The data subject has the right to lodge a complaint with a supervisory authority.

Informing the data subjects

Privacy Notice is available from the controller and the controller’s website.

Erasure of data and storage period

The customer data will be stored for 5 years after the customership has terminated. Marketing data concerning persons that are not customers are stored as long as the person has not prohibited or withdrawn their consent to direct marketing and active marketing operations are conducted. PYN will also delete client’s data from the filing system if the data subject obtains from the controller the erasure of personal data based on law. The data won’t be deleted if it is determined in the law differently or the competent authority has started a process that obliges PYN Fund Management Ltd to retain data or other person has applied for precautionary measures regarding data from the court of Finland.

Approval of Privacy Notice

Privacy Notice has been approved as continuing and been inspected May 24, 2018.